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Using RCRA Interpretations in 2017 and Beyond

Posted on 9/25/2017 by Roger Marks, Ross Kellogg, and James Griffin

Environmental professionals often look to EPA letters of interpretation for clarity on specific hazardous waste management issues that arise at their facilities. Interpretations can be a useful tool for seeing the real-world implications of environmental regulations, but should be viewed with a few cautions in mind.
First, these interpretations are typically addressed to individual facilities that operate under their own unique circumstances. The way EPA interprets a requirement for this facility may not line up exactly with the work you do, your site’s generator status, the type of waste you generate, or the state that you do business in.

A second thing to keep in mind is that interpretations—and the regulatory definitions that inform them—change over time. An interpretation provided in the 1980s may have been superseded by newer interpretation. You should make sure you are seeking out the most recent guidance on these subjects before applying what you learn to your operations.  

The definitions of terms and the applicability of RCRA programs change over time, too. For example, EPA re-defined the term “solid waste” in 2014. Interpretations that rely on the pre-December 2014 definition of solid waste (DSW) therefore may no longer be accurate.  

Where Do I Find RCRA Interpretations?

If you’re looking for RCRA interpretations on a specific management issue or hazardous waste topic, EPA’s RCRA Online portal is a great place to start.

Reshuffled RCRA Rules

Now, there’s something else to keep in mind when you read RCRA interpretations penned before EPA’s Hazardous Waste Generator Improvements Rule took effect in May 2017.

EPA’s Generator Improvements Rule made a number of major changes to the RCRA hazardous waste requirements—new reporting rules, updated container label requirements, new reliefs, changing definitions, and more. EPA also re-organized the generator rules to make them easier to follow and streamline compliance efforts.

Now that the rules have been re-shuffled, EPA interpretations and other hazardous waste guidance documents from public and private sources may contain outdated regulatory references.

It’s a little like asking for directions in an unfamiliar town. A townie might tell you to “turn left where the old barn used to be.” This direction would be fine for someone with historical knowledge about the town, but won’t do you any good if you’re new to the area.

Learn more about the Generator Improvements Rule here. 

Where to Find the RCRA Rules Now 

If you are looking for information about determining generator status, satellite accumulation, container management, emergency preparedness, or many other critical RCRA elements, the information you need may have moved. Below is a short list of critical RCRA requirements and where you can find them now that they’ve moved.
Generator Category Determination
40 CFR 262.13 40 CFR 261.5
Satellite area rules 40 CFR 262.15 40 CFR 262.34(c)
Small Quantity Generator (SQG) requirements 40 CFR 262.16 40 CFR 262.34(d)–(f)
Large Quantity Generator (LQG) requirements 40 CFR 262.17 40 CFR 262.34(a)
RCRA hazardous waste training requirements 40 CFR 262.17(a)
40 CFR 262.34(a) and 265.16
RCRA notification (EPA ID Numbers) 40 CFR 262.18 40 CFR 262.12

The Final RCRA Generator Improvements Webinar of 2017!

Now that EPA’s Generator Improvements Rule is in effect at the Federal level, professionals responsible for hazardous waste management will face questions from colleagues and higher-ups about what must be done to stay in compliance.

Don’t miss the FINAL RCRA update webinar of 2017 on November 29, from 1–3 p.m. This live, instructor-led session will give managers and personnel the answers they need to prepare and plan for big changes to these complex EPA standards.

In October: Meet EPA's annual training requirement with nationally trusted hazardous waste training in Indianapolis, Milwaukee, Detroit, Cleveland, Atlanta, Pittsburgh, Orlando, Nashville, Charlotte, Houston, and Dallas.

Tags: hazardous, hazardous waste management, new rules, RCRA, RCRA Training, waste

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